Privacy Policy

01Introduction

This Privacy Policy applies to grahamronaldhart.co.za (the Website) and to all interactions you have with us, whether through this Website, email or in the course of applying for funding facilitation or otherwise doing business with us.

By using this Website or providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy.

02What Information We Collect

We only collect information that is necessary for the purposes described in this policy. This may include:

Personal identity information

• Full name, ID number, passport number where applicable
• Contact details such as email address, phone number and physical address
• Date of birth where required for verification

Business information

• Company name, registration number, directors and shareholders
• Financial statements, management accounts and bank statements
• Tax clearance, VAT registration and B-BBEE information where applicable

Funding and financial information

• Details of your funding request, including amount, purpose and security
• Information about your existing debt or facilities
• Credit or verification information obtained with your consent

Technical information

• IP address, browser type and device information
• Pages visited, date and time of visits
• Information collected via cookies (see Section 11)

03How We Collect Information

We collect personal information in the following ways:

• Directly from you when you submit an application, contact us or provide documents.
• Automatically through cookies and similar technologies when you use our Website.
• From third parties including verification services, credit bureaus, banks, attorneys and other institutions, with your consent or as required by law.
• From public sources such as CIPC, deeds offices and regulatory registers.

04Why We Use Your Information

We process your personal information for the following purposes:

• To assess and process funding requests
• To verify your identity and the authenticity of documents
• To conduct due diligence and anti money laundering checks
• To prepare, submit and manage funding placements with lenders and private investors
• To communicate with you about your request or placement
• To comply with legal, regulatory and tax obligations
• To protect our legitimate business interests and prevent fraud
• To improve our Website and services

05Legal Basis for Processing

Under POPIA, we rely on the following legal bases to process your personal information:

• Your consent where you have given us explicit consent
• Contractual necessity to enter into or perform a brokerage agreement with you
• Legal obligation to comply with laws such as FICA, tax and anti money laundering requirements
• Legitimate interests to protect our business and prevent fraud, where not overridden by your rights

06Who We Share Information With

We do not sell your personal information. In the course of facilitating your funding request, we may share it with:

• Lenders and private investors in our network for the purpose of assessing and placing your request
• Verification and due diligence partners such as banks, credit bureaus, registries and valuation professionals
• Legal and professional advisers such as attorneys, auditors and accountants
• Regulators and authorities where required by law, including FIC, SARS and the courts
• Service providers such as IT, hosting and communication providers who support our operations under confidentiality obligations
• Third parties with your specific consent, where required

All third parties who process information on our behalf are required to maintain confidentiality and to process information only for the purposes we specify.

07Cross Border Transfers

Your personal information is primarily stored and processed in South Africa. Where information needs to be transferred outside South Africa, for example to an offshore service provider, we will ensure that the recipient is subject to laws or contractual obligations that provide an adequate level of protection substantially similar to POPIA.

08How Long We Keep Information

We retain personal information only for as long as necessary for the purposes described in this policy and in accordance with applicable legal retention periods. As a general guide:

• Enquiries that do not proceed are retained for a reasonable period to allow follow up and then securely deleted
• Active engagements and placements are retained for the duration of the relationship plus the applicable legal retention period
• FICA and anti money laundering records are retained for the minimum periods required by law, typically 5 years or more
• Tax and financial records are retained in accordance with SARS requirements

09How We Secure Information

We take the security of your personal information seriously. Measures we take include:

• Restricted access to personal information on a need to know basis
• Secure storage of physical and electronic documents
• Encrypted transmission of sensitive information where appropriate
• Regular reviews of our security and privacy practices
• Confidentiality obligations on all staff and third parties

10Your Rights

Under POPIA, you have the following rights in relation to your personal information:

• Right to access a copy of the personal information we hold about you
• Right to correction of inaccurate information
• Right to deletion of your information, subject to legal retention requirements
• Right to object to the processing of your information in certain circumstances
• Right to withdraw consent where processing is based on consent
• Right to complain to the Information Regulator of South Africa

To exercise any of these rights, please contact us at enquiries@grahamronaldhart.co.za. We may ask you to verify your identity before processing your request.

11Cookies & Tracking

Our Website may use cookies and similar technologies to improve your browsing experience and to understand how visitors use the site. Cookies are small text files stored on your device.

Types of cookies we may use:

• Essential cookies required for the Website to function properly
• Analytics cookies that help us understand traffic and usage patterns
• Preference cookies that remember your settings and preferences

You can control or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of the Website.

12Children's Privacy

Our services are intended for businesses and adults. We do not knowingly collect personal information from children under the age of 18. If you believe a child has provided us with personal information, please contact us so we can remove it.

13Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or other factors. Any changes take effect when they are published on this page.

We encourage you to review this page periodically so that you remain aware of how we protect your information.

14Contact & Complaints

If you have any questions about this Privacy Policy or wish to exercise any of your rights, please contact us at enquiries@grahamronaldhart.co.za or visit www.grahamronaldhart.co.za.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Regulator of South Africa:

• Website: www.justice.gov.za/inforeg
• Email: complaints.IR@justice.gov.za